ML20137S582
| ML20137S582 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/08/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-1000, NUDOCS 9704150178 | |
| Download: ML20137S582 (4) | |
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C. K. McCoy Southorn NuclCar Vice President Operating Company,Inc.
Vogtle Project 40 Invecess Center Parkway PD. Box 1295 Birmingham Alabama 35201 Tel 205 992.7122 fax 205 9920403 SOUTHERN L
' April 8, 1997 COMPANY Docket Nos. 50-424 50-425 LCV-1000 U. S. Nuclear Regulatory Commission A'ITN: Document Control Desk Washington, DC 20555 VOGTLE ELECTRIC GENERATING PLANT QUALITY ASSURANCE PROGRAM CHANGE DESIGN CHANGE VERIFICATION PROCESS Southern Nuclear Operating Company, Inc. (Southern Nuclear) hereby requests a change to the Quality Assurance Program as described in the Vogtle Electric Generating Plant Units 1 and 2 Final Safety Analysis Report (FSAR), Section 17.2.3.G, related to the design verification sequence for procurement of components.
Southern Nuclear proposes to change the FSAR to allow for completion of design verification prior to relying upon the item to perform its function. Attachment 1 provides the proposed wording changes to the FSAR.
t Currently, the FSAR requires that design verification (if other than by qualification testing of a prototype or lead production unit) be completed prior to release for procurement, manufacturing, and installatiod, or to another organization for use in other design activities. This requirement was included in the original FSAR particularly for pre-operational facilities where large scale " untested" design work necessitated early resolution of design problems prior to a commitment of excessive amounts of design and construction resources. This change to the FSAR will not eliminate the design verification. The design verification will continue to be required prior to relying on the item to perfonn its function. Therefore the effect on the quality of the design change relative to safety will be neutral. The benefits of the change are that design verification activities will be allowed to proceed in conjunction with procurement, manufacturing and installation. In either case the required verification will be completed prior to placing the modification into operation. Operational design changes are not nonnally sufficiently complicated to warrant such a prescriptive approach to i nplementation. Furthermore, neither Regulatory Guide 1.64 " Quality Assurance l
Requirements for the Design of Nuclear Power Plants" nor ANSI N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants" as described in FSAR section 1.9.64 require design verification prior to procurement, manufacturing, etc.
Pursuant to the requirements of 10 CFR 50.54 (a), Southern Nuclear has concluded that there would be no significant reduction in commitments in the Quality Assurance Program as a result of this change. However,
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U. S. Nuclear Regulatory Commission Page 2 Southern Nuclear is requesting NRC approval before implementing this change. Following NRC approval, Southern Nuclear will update its internal procedures and the FSAR to incorporate these changes.
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C. K. McCoy /
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Attachment i
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Southern Nuclear Oneratine Comnany i
Mr. J. B. Beasley j
Mr. M. Sheibani j
NORMS j
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U.S. Nuclear Reculatory Commission i
Mr. L; A. Reyes, Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR i
Mr. C. R. Ogle, Senior Resident Inspector, Vogtle l
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ATTACilMENT 1 PROPOSED FSAR MARKUP l
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VEGP-FSAR-17 4
C.
Qualification tests to verify the adequacy of design are performed, as applicable, using the most adverse i
specified design conditions practical to provide or to a
simulate.
i D.
Design changes are reviewed to ensure that design criteria are defined and that inspection and test i
criteria are identified.
E.
New or innovative designs will be subjected to 2
comprehensive design review, which may include calculational checks or a testing program under adverse design conditions.
F.
Written procedures will require a documented check to verify the dimensional accuracy and completeness of design drawings and specifications.
efede.
G.
Designbferific:tien, if ether thn by qu:lific:ti =
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g tetting Of pretetyp: er 10:d pr:ducti:n 2 nit, i:
r c, pl= tee pri== te
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1er pr;;m;e=;nt,
- nufacturing, and inet:ll:ti:n, er :: :n th:r 3
- nni
- :tien der us: in :th r d::ign :stivities.
In
- hare creer ':?here *his ti=ing ::nn:t h n;t, the d;;ign verifientien nry S: d:f:rr:d, pr;viding th:t th; j
justification for thi: ::tien i: d umented and that th: unverified p;rti:n ;f the design cutput-document j
j
=ad all eesign output-decuments, b; sed-ort-the j
"a"-aifi A d=*e 2re ppropriately identified and L
entr ll:d.
In all c&ses.f~erification is completed v
prior to relying upon the item to perform its function.
There is a comprehensive audit system to verify that the design control system maintained by the responsible organizations durir.g the operation of the VECP is adequate and functioning properly.
Any errors or deficiencies found in the design process or the design itself are documented and corrective action taken, as described in subsection 17.2.16.
Design documents and revisions thereto are controlled and distributed as described in subsection 17.2.6.
Records of design activities and design changes are collected, stored, and maintained in a systematic manner to prevent inadvertent use of superseded documents.
j VEGP plant procedures require that plant personnel are made aware of design changes / modifications which may affect the performance of their duties.
Methods by which plant personnel are made aware will include procedure revision training, night orders, and structured training for major modifications.
17.2.3-3